1 IN THE UNITED STATES DISTRICT COURT DISTRICT FOR THE WESTERN DISTRICT OF LOUISIANA AARON GUIDRY, member of Warriors For Christ and Special Forces Of Liberty, LT MARK CHRISTOPHER SEVIER, De Facto Attorney Generals and Special Forces Of Liberty, SGM JOHN GUNTER JR, Special Forces Of Liberty, WHITNEY KOHL, Special Forces Of Liberty, JOAN GRACE HARLEY, Special Forces Of Liberty, PASTOR RICH PENKOSKI, Warriors For Christ and Special Forces Of Liberty Case No: V. TERESA ELBERSON, director of the Lafayette Public Library, JOHN BEL EDWARDS, in his official capacity as Governor of Louisiana, JEFFREY MARTIN LANDRY, in his official capacity as Attorney General of Louisiana, Hon. STUART R. SHAW, in his official capacity as the Red River Parish Clerk, TONY ROSWARSKI, in his official capacity as Mayor of Lafayette Defendants COMPLAINT FOR INJUNCTIVE RELIEF INTRODUCTION Marriagerestorationact.com Silence in the face of evil is itself evil: God will not hold us guiltless. Not to speak is to speak. Not to act is to act. - Dietrich Bonhoeffer
2 1. NOW COMES, Plaintiffs, Aaron Guidry, a member of Louisiana chapter of warriors for Christ and Special Forces Of Liberty and louisiana taxpayer; Mark Christopher Sevier Esq., a Louisiana taxpayer, former Command Judge Advocate General, Congressional Liaison between the House and Senate Special Investigation Unit on Judicial Corruption, a member of the De Facto Attorney Generals, a member of the Special Forces Of Liberty, and self-identified objectophile; Grace Harley, a taxpayer, a member of the Special Forces Of Liberty, and a former transgender activist, who now self-identifies as a polygamist; Whitney Kohl, a taxpayer, a member of the Special Forces Of Liberty, and former self-identified lesbian activist, who now self-identifies as a polygamist, and SGM John Gunter Jr, a taxpayer, a member of the Special Forces Of Liberty, Federal and State lobbyist, and self-identified polygamists; and Pastor Rich Penkoski, a member of the Louisiana Chapter of Warriors for Christ and Special Forces of Liberty seeking preliminary and permanent injunctive relief. The Plaintiffs are part of the Special Forces Of Liberty, which is working on tax legislation in this State. (See Declaration of the Special Forces Of Liberty;; see the Human Trafficking Prevention Act and the Admission Act). The Plaintiffs, as card carrying members of the Lafayette Public Library and as ardent tax lobbyist in Louisiana, have a vested interest in how the State spends tax dollars generated by the Plaintiffs legislative efforts. The Plaintiffs have a logical nexus to the Library, having interfaced with it and having scheduled meetings there for secular purposes. Despite their interaction with the library, the Plaintiffs have been denied equal treatment under the law for their religious and political beliefs compared to the treatment of devout Secular Humanists, who self-identify as transgender and who are proactively seeking to erode community standards of decency and entangle the government with their narrow, shallow, and exclusive religious
3 worldview. The Plaintiffs object to self-identified transgenders exploiting the state s endorsement of their religious ideology in an government endorsed effort to brainwash and indoctrinate minors to a religious worldviews on sex, faith, truth, gender, morality, and marriage in a manner that excessively entangles the government with the religion of postmodern-western-individualistic-moral relativism - referred to mainly by the Plaintiffs and the United States Supreme Court as Secular Humanism. By endorsing transgenderism in the manner complained of the city of Lafayette is relegating Christians to second class citizens. Because the Drag Queen Story hour is scheduled for October 6, 2018, the Petitioners seek an immediate ex parte preliminary injunction until it can be resolved whether the Library s decision to endorse the Drag Queen Story hour violates the First Amendment Establishment Clause of the United States Constitution. Like in Obergefell v. Hodges, 135 S.Ct (2015), this case concerns only what states may do under the Constitution in determining (1) how the Constitution permits the States to legally define marriage, (2) which types of marriages the States can legally recognize, (3) whether State facilities can host one religious organization over another, and (4) how the state is required to respond to self-asserted sex-based identity narratives that are questionably real, moral, and have a tendency to erode community standards of decency. The Plaintiffs seek a declaration and preliminary and permanent injunction under the First Amendment Establishment Clause to enjoin the State from (1) legally recognizing gay marriage, from (2) enforcing any conversion therapy ban, from enforcing any policy that endorses transgenderism, from (3) enforcing any policy that treats sexual orientation as if it is a civil rights issue predicated on immutability, from (4) enforcing any policy that allows for individuals to change their
4 self-evident gender to a different on their birth certificate, or any other policy that respects the dogma from the LGBTQ church. Those policies violate the First Amendment Establishment clause by a landslide by (1) constituting a non-secular sham, for (2) serving as an defensible legal weapon against non-observers, and for (3) excessive entanglement of government with the religion of Secular Humanism. See the attached Marriage And Constitution Restoration Act, concurrent resolution, and resolution that Secular Humanism is a religion templates forwarded to legislative research counsel for drafting to be introduction at the 2019 legislative session by sponsors assigned to the committees with paramount jurisdiction for vote. The First Amendment Establishment Clause of the United States Constitution reads [the government] shall make no law respecting an establishment of religion. The First Amendment Establishment Clause applies to the State of Louisiana through the Fourteenth Amendment. The Defendants are guilty of enforcing policies that respect LGBTQ policies in a manner that fails all three prongs of the Lemon Test set forth in Lemon v. Kurtzman, 403 U.S. 602 (1971) from every angle. To pass muster under the Establishment Clause, a practice must satisfy the Lemon test, pursuant to which it must: (1) have a valid secular purpose; (2) not have the effect of advancing, endorsing, or inhibiting religion; and (3) not foster excessive entanglement with religion. Government action violates the Establishment Clause if it fails to satisfy any of these prongs. Edwards, 482 U.S. 578 at 583; Agostini v. Felton, 521 U.S. 203, 218 (1997). To refresh recollection, here is a video that explains the Lemon Test in a clear manner: 2. In view of the testimony of ex-gays, medical professionals, persecuted christians, and ministers, gay marriage policy, sexual orientation discrimination statutes, pro-transgender city ordinances, conversion therapy bans, library endorsed drag queen story hour etc violate all three
5 prongs of the Lemon test by a landslide in their making and in their enforcement because sexual orientation has nothing to do with American tradition or heritage or immutability, but rather, the evidence shows that sexual orientation is a mythology, dogma, orthodoxy, and theocratic ideological doctrine that is predicated on a series of unproven faith-based assumptions and naked assertions and is inseparably linked to the religion of Secular Humanism. (DE_ Lisa Boucher 1-10; DE _ Quinlan 1-37; DE _ Pastor Cothran 1-50; DE _ Dr. King 1-20; DE _ Dr. Cretella 1-20; DE _ Goodspeed 1-20; DE _Grace Harley 1-25; DE _Kohl 1-12; DE _ Pastor Cuozzo; 1-21; DE _ Pastor Farr 1-33; DE _ Pastor Penkoski 1-34; DE _ Pastor Cairns 1-30;; DE _Christian Resistance 1-21; DE _ Special Forces Of Liberty 1-34). See Amicus Briefs of the Center For Garden State Families; the WW Bridal and the American Family Association of PA; National Alliance of Black Pastors; and the Coalition of Doctors Defending Reparative Therapy. The United States Supreme Court has already recognized and reaffirmed that that Secular Humanism is a religion for the purposes of the First Amendment Establishment Clause in Torcaso v. Watkins, 367 U.S. 488 (1961) and Edwards v. Aguillard, 482 U.S. 578, 583 (1987)( Among religions in this country, which do not teach what would generally be considered a belief in the existence of God, are Buddhism, Toaism, Ethical Culture, Secular Humanism, and others. See Also Washington Ethical Society v. District of Columbia, 101 U.S. App. D.C. 371, 249 F. 2d 127 (1957); 2 Encyclopaedia of the Social Sciences, 293; J.Archer, Faiths Men Live By , (2d ed. revised by Purinton 1958); Stokes & P feffer,supra, n.3,at 560. Welsh v. U.S, U.S. 333 (U.S. Cal. June 15);; Wells v. City and Cnty. of Denver, 257 F.3d 1132 (2001)). Nearly all of the Federal of Appeals have also recognized that Secular Humanism is a religion for the purposes of the First Amendment
6 Establishment Clause. The Louisiana State legislature intends to hammer home the fact that Secular Humanism is a religion as the Supreme Court found long before Obergefell was decided and that LGBTQ orthodoxy is insperably linked to the religion of Secular Humanism in a 1 manner that bars the government from respecting it. Plaintiffs Harley, Sevier, Gunter, and Kohl join Plaintiffs Penkoski and Guidry in their the primary cause for injunctive and declaratory relief under the First Amendment Establishment Clause. The evidence shows that the First Amendment Establishment Clause balanced with the Free Exercise Clause has exclusive jurisdiction over how the State is permitted to legally define marriage. However, Plaintiffs Harley, Sevier, Gunter, and Kohl exercise their right to plead in the alternative under FRCP 8(e)(2), seeking to force the government to legally recognize more progressive forms of parody marriage, to include polygamy and man-object marriage, if and only if marriage is a matter of civil rights that falls within the jurisdiction of the Fourteenth Amendment Equal Protection and Substantive Due Process Clauses as the United States Supreme Court found in Obergefell v. Hodges, 135 S.Ct (2015) for reasons that were based exclusively on emotion. 1 In Real Alternatives, the Seventh Circuit Court of Appeals stated: we detect a difference in the philosophical views espoused by [the litigants], and the secular moral system[s]...equivalent to religion except for non-belief in God that Judge Easterbrook describes in Center for Inquiry, 758 F.3d at 873. There, the Seventh Circuit references organized groups of people who subscribe to belief systems such as Atheism, Shintoism, Janism, Buddhism, and secular humanism, all of which are situated similarly to religions in everything except belief in a deity. Id. at 872. These systems are organized, full, and provide a comprehensive code by which individuals may guide their daily activities. Instead having across or the ten commandments, the LGBTQ church has the gay pride flag and their own commandments,such as if you disagree with LGBTQ ideology you are a bigot worth marginalizing. The unproven naked truth claims evangelized by the LGBTQ church such as (1) there is a gay gene, that (2) people can be born in the wrong body, that (3) same-sex sexual activity checks out with the human design, that (4) same-sex buggery is not immoral, and that (5) people come out of the closest are baptized gay consists of a series of unproven faith based assumptions that are implicitly religious and take a huge amount of faith to believe are even plausible.
7 3. All of the Plaintiffs acknowledge that if the State were to legally recognize other forms of non-secular parody marriages, it would only further entangle the government with the religion of Secular Humanism and further erode community standards of decency. 4. The Plaintiffs understand and acknowledge that under the Free Exercise Clause of the United States Constitution, Plaintiffs Harley, Sevier, Gunter, and Kohl have the same right as self-identified homosexuals and transgenders to self-identity as anything they would like to, cultivating their own self-asserted sex-based identity narrative that erodes community standards of decency, if that is what they want to do. That is, the Plaintiffs acknowledge and understand that citizens of Louisiana have the right under the Free Exercise Clause to (1) self-identify as anything they would like, to include a homosexual, transgender, zoophile, wizard, chicken sandwich, to (2) have wedding ceremonies, and to (3) live as married people do for better or worse. 5. The Plaintiffs have no objection to the Drag Queen Story hour being held on private property. However, the Plaintiffs object to the public library s endorsement of Drag Queen Story hour because the public library is a government actor that is endorsing non-secular activity in an manner that is excessively entangling the government with the religion of Secular Humanism in a manner that relegates non-observers of the religion of Secular Humanism to second class citizens. B. JURISDICTION AND VENUE 6. This action raises questions under the Constitution of the United States and 42 U.S.C. 1983, and thus this Court has jurisdiction over all claims for relief pursuant 28 U.S.C (Federal Question Jurisdiction). Venue is proper in this Court pursuant to 28 U.S.C. 1391(b) because all
8 Defendants reside in this District and in this State. Venue is also proper because a substantial part of the events giving rise to the claims occurred in this district. This Court has the authority to enter a declaratory judgment and to provide preliminary and permanent injunctive relief pursuant to Rules 57 and 65 of the Federal Rules of Civil Procedure, and 28 U.S.C and THE PARTIES 7. Plaintiff Aaron Guidry is a Louisiana resident, like the other Plaintiffs. He is the Louisiana chapter leader of Warriors For Christ and the Special Forces Of Liberty, an aggressive and lobbying groups that the other Plaintiffs belong to. The Special Forces Of Liberty promotes common sense policies that are not based off emotion but are based on common sense, logic, and what the written Constitution says. Plaintiff Guidry has been going to the Lafayette public library since he was a child. It is a sentimental place for him that is marked by innocence. Plaintiff Guidry is a card carrying member of the Lafayette Public Library, along with most of the other Plaintiffs. Plaintiff Guidry, like the other Plaintiffs is deeply offended that the Lafayette Library is hosting the Drag Queen Story hour in an effort to indoctrinate minors to a religious ideology that does not check out with the human design on public grounds in a facility paid for by tax dollars. Plaintiff Guidry, like the other Plaintiffs, believe that homosexuality is immoral, obscene, subversive to human flourishing, and non-secular in nature. Plaintiff Guidry, like the other Plaintiffs does not want the State to endorse - either directly or indirectly - anything that has to do with Secular Humanism, which includes homosexual and transgender ethos.
9 8. Pastor Penkoski is the founder of Warriors For Christ. Pastor Penkoski has been viciously persecuted by the LGBTQ community because he believes that the Bible s take on sex and sexuality is objective right and that when followed it leads to maximized human flourishing. Pastor Penkoski, sought, but was not permitted to give a rebuttal to the transgender story hour at the Lafayette public library on October 6, 2018, and he was treated like a second class citizen because the Defendants are putting the religion of Secular Humanism over other religions, like Christianity. 9. The Plaintiff Sevier is a former Judge Advocate General, who is the author of a litany of legislative measures. Plaintiff Sevier was in good standing with the Tennessee Supreme Court. He sued the Tennessee Board of Professional Responsibility that is part of the Tennessee Supreme Court for unethically targeting him because he is a Christian and a whistleblower. The Tennessee Supreme Court hatched a reprisal plan to shut him up by abusing the mental health profession in the same way that it was abused against filmmaker Dinesh D Souza in United States v. D'Souza, 1:14-cr (S.D. N.Y. 2014), who was targeted by the Obama administration for making films that embarrassed the former President by telling the truth. Plaintiff Sevier has been mercilessly targeted by the Tennessee Board Of Professional Responsibility for purely religious and political reasons. Plaintiff Sevier will move to join the current attorney of record, if the motion is denied, Plaintiff Sevier will add members of the Board 2 as co-defendants. Where there is a lot of free speech, there is a lot of stupid speech, 2 Plaintiff Sevier and the Special Forces Of Liberty have a vested interest in deterring state agencies, like Colorado Civil Rights Commission, ran by Aubrey Elenis, that targeted Christian baker Jack Phillips and the Wyoming Commission on Judicial Conduct and Ethics, chaired by Wendy Soto, that targeted the Honorable Judge Neely because of political and religious differences. What Krisann Hodges, Aubrey Elenis, and Wendy Soto all have in common is that they are females who are brainwashed by culture and who obsessively work to entangle the government with the religion of Secular Humanism because they lack the character fitness to know the objective difference between real and fake, right and wrong, and secular and non-secular.
10 accordingly, under the Free Exercise Clause, Plaintiff Sevier self-identifies as an objectophile, as is his right, just as a person can self-identify as a transgender. Plaintiff Sevier is a taxpayer, 3 whose direct efforts impact the tax revenue of this state immensely. (See Declaration of the Special Forces Of Liberty 1-34). Plaintiff Sevier has been mercilessly assaulted by the LGBTQ church for demonstrating repeatedly that Obergefell was a dishonest sham predicated on an unprincipled ploy that lacked a primary secular purpose and has lead to a host of secondary harmful effects - see the declaration of Lisa Boucher from WW Bridal. 10. In view of the Free Exercise Clause, Plaintiff Gunter self-identifies as a polygamists. Plaintiff Gunter is a taxpayer of this State, whose direct efforts on lobbying and writing 4 legislation impacts the tax income of this State. 11. Plaintiff Kohl was straight. She was engaged to a man. She had some traumatic experiences in dating males and elected to self-identify as a lesbian in conforming to the messages that self-identified transgenders intend to preach within the four walls of the Lafayette Public Library to minors with the Defendants support. Plaintiff Kohl legally married a woman once it was permitted, only to then end the marriage. She realized that being in a romantic relationship with a woman was worse than being married to a man. She now self-identifies as a polygamist in view 3 Objectophillia: Object sexuality or objectophilia is a form of sexuality focused on particular inanimate objects. Those individuals with this expressed preference may feel strong feelings of attraction, love, and commitment to certain items or structures of their fixation. In step with his self-asserted sex-based identity narrative, he sought a marriage license from the Parish Clerk - having met all of the requirements - and was arbitrarily denied for procedural and other reasons that self-identified homosexuals once were. The Plaintiffs have paid taxes in this state and those taxes have gone towards the funds that connect with supporting and recognizing other forms of parody marriage. 4 Plaintiff Gunter wants to marry multiple wives in this State with the state s endorsement of his worldview. He wants to add Plaintiff Kohl and Plaintiff Grace as his spouses. Plaintiff Gunter - having met all of the requirements to marry - sought a marriage license from the Clerk and was denied because he is part of the true minority of the sexual orientation suspect class. (See Declaration of Gunter). As a lobbyist and member of the Special Forces Of Liberty, he is working in this State to pass legislation that will impact the States general fund. He is a taxpayer of this state. (See Declaration of Special Forces Of Liberty 1-34).
11 of the Free Exercise Clause. She wants to legally marry Plaintiffs Gunter and Grace Harley in Louisiana if and only if self-identified homosexuals marriages are legally recognizable. (See Declaration of Kohl). She is part of the Special Forces Of Liberty who is pushing legislation in this State that substantially impacts the State s general fund annually. 12. Plaintiff Grace was born as a African American woman but self-identified as a transgender man for 18 years. She went from Joan the woman to Joe the man. At one point, she really believed that she was born in the wrong body. She accepted that idea on faith having been indoctrinated by the same ideological dogma that the Lafayette Library has endorsed by hosting the Drag Queen Story hour. In 1992, Plaintiff Harley left the transgender identity narrative behind completely, having been radically transformed by the same Christ figure that Jack Phillips treats as his King. In view of the Free Exercise Clause, Plaintiff Harley now self-identifies as a polygamist. She has been persecuted relentlessly by intolerant believers in the homosexual ideological religion because her testimony is fatal to the idea that gay rights are civil rights based on immutability (See Declaration of Grace Harley). As an African American female who experience racial discrimination as a child growing up in the deep south, Plaintiff Harley is deeply offended that the State would treat the LGBTQ plight as if it were equal to the race-based civil rights plight, whereas only the race-based civil rights plight was based on immutability and genetics. 13. Defendant Teresa Eleberson is the director of the Lafayette public library. Having been brainwashed by the narrow minded unexamined assumption of the superiority of our cultural moment, Defendant Eleberson objectively cannot tell the difference between right and wrong, real and fake, and secular and non-secular. Defendant Eleberson, like the other Defendants, is a
12 state actor who is misusing her position in government to excessively entangle the government with the religion of Secular Humanism. 14. Defendant John Bell Edwards is the Governor of the State of Louisiana ( Governor ). In his official capacity, the Governor is the chief executive officer of the State of Louisiana. It is his responsibility to ensure that the laws of the State are properly enforced and that the government is not engaging in policy that violates the United States Constitution. The Governor is overseeing laws that provide self-identified homosexuals with a constellation of taxpayer funded benefits in a manner that excessively entangles the government with the largest denomination within the church of Secular Humanism, puting the religion of Secular Humanism over non-religion. 15. Defendant Jeffrey Martin Landry is the Attorney General of the State of Louisiana ( Attorney General ). In his official capacity, the Attorney General is the chief legal officer of the State of Louisiana. It is the Attorney General s duty to see that the laws of the State are uniformly and adequately enforced. The Attorney General is enforcing laws that provide benefits to individuals who self-identify as homosexual but not to individuals who self-identify as polygamists and objectophiles who are more progressive. The Attorney General s office is giving special treatment to individuals who self-identify as homosexual but not those who have a less popular sex-based self-asserted identity narrative for reasons that are arbitrary - demonstrating that pro-gay policies are non-secular shams. The is the Attorney General is overseeing the distribution of a constellation of benefits to self-identified homosexuals which flow from the coffers of the State s general fund in a manner that that is causing the Plaintiffs to be complicit in endorsing a worldview and sexual practices that they believe are self-evidently immoral, that are potentially removed from reality, and that have a tendency to erode community
13 standards of decency. By filing this lawsuit, the Plaintiffs are doing the Attorney General s job for him due to the Attorney General s refusal to understand the First Amendment Establishment Clause and the Free Exercise Clause of the First Amendment and his duty under Article VI to uphold the United States Constitution. 16. Defendant Hon. Stuart R. Shaw is the Marriage Supervisor and the Clerk of the Red River Parish. The Clerk is responsible for maintaining vital records of marriages, issuing marriage licenses, and performing civil marriage ceremonies. Defendant Shaw issues marriage licenses to individuals who self-identify as homosexual, but he refuses to give marriage licenses to zoophiles, objectophiles, and polygamists license on a basis that can only be described is arbitrary. The Red River Parish Clerk s office has attempted to refuse to issue marriage licenses to self-identified homosexuals because the Clerk believed that doing so was immoral. However, now the Plaintiffs have served the Red River Parish Clerk s office with the controlling Constitutional basis for why the Clerk must never issue parody marriage licenses - it is an evil that the Establishment Clause simply will not allow. By issuing marriage licenses to individuals who seek to enter into a parody marriage, the Parish is excessively entangling the government with the religion of Secular Humanism. 17. Defendant Tony Roswarski is the Mayor of Lafayette. The Lafayette policy implementation falls under his jurisdiction as the chief executive of the city. The evidence shows that Honorable Mayor has been looking for a legal basis to stop the Drag Queen Story hour from taking place under his watch. The Plaintiffs are providing the Honorable May with the legal bases for doing so for two independent reasons. First, the Mayor has a duty under Article VI of the United States Constitution to ensure that the city library does not engage in policies that violate the United
14 States Constitution. The United States Constitution preempts state law and policy. The Libery is a state actor. The Honorable Mayor has a duty under Article VI to shut down the transgender story hour that is scheduled for October 6, 2018 because it is non-secular activity that violates prong I of the Lemon Test and because it has the effect of excessively entangling the government with the religion of Secular Humanism in violation of prong II. Accordingly, the Honorable Mayor is Constitutionally required by the Establishment Clause, as a matter of duty, to stop the Transgender story hour from going forward for the same reasons that the remaining Defendants and this Honorable Court are required to get out of the parody marriage business and to disentangle the government from the LGBTQ community. The fact that the Library picked out the books to be read at the transgender story hour and the fact that United States Supreme Court has been especially vigilant from not allowing state assets to be used to indoctrinate minors to a particular religious worldview makes it mandatory for the Mayor to stop the Lafayette Public Library from converting into a cathedral that is crafted to introdrination minors to the dehumanizing theocratic dogma of Secular Humanism. Furthermore, the Plaintiffs are providing the Honorable Mayor with a second insurmountably legal basis to enjoin the Drag Queen Story hour from taking place at the public facility that would survive first amendment heightened scrutiny if challenged. The self-identified transgenders intend to engage in activity that erodes community standards of decency. (A Christian Bible Study held by Pastor Penkoski or Plaintiff Guidry does not erode community standards decency - and that is a distinction with a difference). The city has a compelling interest to uphold community standards of decency. Paris Adult Theatre I v. Slaton, 413 US 49, at 63, 69 (1973). It remains true now as it has always that any school boy knows that a homosexual act is immoral, indecent, lewd, and obscene. Adult
15 persons are even more conscious t hat this is true. Schlegel v. United States, 416 F. 2d 1372, 1378 (Ct. Cl. 1969). The United States Supreme Court has made crystal clear long before the Obergefell and Windsor putsch to simply adjust the definition of obscenity to social realities has always failed to be persuasive before the Courts of the United States. Ginsberg v. New York, 390 U.S. 629, , 88 S. Ct. 1274, 20 L. Ed. 2d 195 (1968); Mishkin v. State of New York, 383 U.S. 502, 509, 86 S. Ct. 958, 16 L. Ed. 2d 56 (1966); and Bookcase, Inc. v. Broderick, 18 N.Y.2d 71, 271 N.Y.S.2d 947, 951, 218 N.E.2d 668, 671 (1966). The Mayor has a compelling interest to shut down the Drag Queen Story Hour because its endorsement by the public library erodes community standards of decency and normalizes false permission giving beliefs about sex that do not check out with the human design and the way things are as a matter of self-evident fact-based observation. The Honorable Mayor has a duty to shut down the Drag Queen Story hour from going forward for the same reason he would need to shut down Strip Club Story Hour hosted by Anastasia, Objectophile Story Hour hosted by Lieutenant Sevier or Polygamy Story Hour for minors hosted by SGM Gunter. In view of these two different reasons, if the mayor does not shut down the Drag Queen Story Hour the Special Forces of Liberty will file additional lawsuits against the Mayor s office for dereliction of duty. 18. Defendants, and those subject to their supervision, direction, and control, are responsible for the enforcement of marriage policies, pro-transgender policies, and the enforcement of sexual orientation discrimination statutes that assert that gay rights are civil rights, and other laws and policies that have caused the Plaintiffs and others to be injured in their taxpayer status and socially marginalized for believing in a different worldview other than mainstream Secular Humanism that is advocated by the Democratic Party ad nauseum, as a result of their animus
16 towards Constitutional supremacy and absolute transcultural truth that has been woven into the fabric of the universe. The relief requested in this action is sought against each Defendant, as well as against each Defendant s officers, employees, and agents, and against all persons acting in cooperation with Defendant(s), under their supervision, at their direction, or under their control. Each of the Defendants has a duty to uphold the United States Constitution under Article VI have failed to do so. UNDISPUTED MATERIAL FACTS 19. The Plaintiffs repeat and incorporate by reference all of the above allegations of this Complaint as though fully set forth herein. The Plaintiffs have no objection to the Drag Queen Story Hour taking place at Delta Lambda Phi or at any other private location. The Defendants recognize, respect, and defend the right for individuals to self-identify as anything they would like, even if the identity narrative is self-evidently depersonalizing, dehumanizing, damaging, destructive, desensitizing, and dangerous. The Plaintiffs believe that the members of Delta Lambda Phi have the right to self-identify as transgender in the same way that they have the right to self-identify as sexualized chicken sandwiches. Defendant Eleberson knows or should know that the whole purpose for having the Drag Queen Story Hour at the public library is to convey that government has established Secular Humanism as the supreme state religion through symbolic endorsement. 20. Having all been viciously persecuted and hunted by the deeply intolerant and truth allergic LGBTQ community, the Plaintiffs are deeply offended that the tax fund library is hosting the Drag Queen Story Hour at a publicly funded facility. The Plaintiffs use the library for secular purposes and the Drag Queen Story Hour causes the Plaintiffs to feel like second class citizens,
17 since they do not believe in the narrow minded and exclusive religion of Secular Humanism, expressive individualism, also referred to as postmodern western individualistic moral relativism, as advocated by the LGBTQ church. The purpose of the Library hosting the Drag Queen Story Hour is to relegate citizens who have the common sense and humility to believe in absolute truth to second class citizens - communicating that the State of Louisiana believes that their worldview is inferior to the idea that there is more than two genders or that people can be born in the wrong body - which are nothing more than unproven faith based assumptions and naked assertions that are themselves implicitly religious. 21. The Plaintiffs use the public library for secular purposes. They have worked on legislative within the library to include legislative measures like the (1) Admission Act, (2) the Human Trafficking And Child Exploitation Prevention Act, (3) the Stop Social Media Censorship Act, (4) the Life Appropriation Act, (5) the Elevated Marriage Act (referred to as the Covenant Marriage Act by Arkansas), (6) the resolution that resolves that Secular Humanism is a religion for the purposes of the First Amendment Establishment Clause and (7) the Marriage And Constitution Restoration Act and concurrent resolution. See also the resolution that declares that pornography online is creating a public health crisis. The Plaintiffs had made plans to bring their kids or other minors to the library on October 6, 2018, and they do not want themselves or minors who are under their care to be exposed to the sermonizing by self-identified transgenders who intend to indoctrinate minors to their religious faith-based ideology that is potentially implausible and is without question obscene and non-secular. The Plaintiffs object to the public library being converted into a temple for religious indoctrination of minors to a wordview on sex
18 that was basically illegal until recently, when Lawrence v. Texas, 539 U.S. at 579 overturned Bowers v. Hardwick, 478 U. S. 186 (1986). 22. Having been viciously targeted and abused by phony tolerant and intellectually dishonest Secular Humanism, the Plaintiffs know first hand that transgender ideology plunges individuals into a further state of intellectual dishonesty and desensitization which makes them even more self-entitled and dangerous to citizens who believe in absolute truth. The Plaintiffs are deeply offended that government actors would symbolically and directly endorse such flagrant non-secular conduct that prides itself on eroding community standards of decency and seeks to hijack the race-based civil rights movement in manner that manages to be racially and sexually exploitative. Because Defendant Eleberson is hosting the Drag Queen Story Hour she can only be described as a racists who has animus towards Christians or she is a person who cannot think logically, either way, her decision to host the Drag Queen Story Hour and to pick out the books for the meeting offends the Plaintiffs. 23. Many of the Plaintiffs have library cards from the Lafayette Public library. Plaintiff Guidry has been going to Lafayette library off and on since he was a child. The Plaintiffs made plans to be in the library on October 6, 2018 during the Drag Queen Story Hour to discuss the Marriage And Constitution Restoration Act and the Secular Humanism Resolution, and how they plan to force all 50 states and the Federal government to completely disentangle itself with the LGBTQ ideology, since that is what the Establishment Clause requires. The Plaintiffs plan to discuss their proposed legislative findings and the different takes by various Attorney Generals throughout the United States who have pledged to defend the proposed legislation and abandon Obergefell as
19 Article VI requires. The Plaintiffs purpose in using the library on October 6, 2018 is secular in nature. 24. Agents from the Library selected the books for the Drag Queen Story hour. They welcomed and encouraged the story hour to take place and have engaged in a series of other measures to make it clear that the Library itself was officially endorsing the drag queen story hour on behalf of the state of Louisiana, and giving preferential treatment to the religion of Secular Humanism over non-religion. The Plaintiffs believe that emotional reasons do not allow the government to usurp the Establishment Clause. 25. Just because Secular Humanists are too intellectually dishonest and blind to see that their take on faith, sex, gender, morality, marriage, and truth is religious in nature does not mean that it is not. The Plaintiffs believe that it is not necessarily true that times can blind, as Chief Justice Roberts said in his Obergefell dissent, it is that a subscription to moral relativism that blinds. The Plaintiffs object to the government endorsing a religious worldview that plunges citizens into intellectual darkness. After all, without truth, there is no freedom. Freedom comes from the truth. LGBTQ ideoloty and transgender orthodoxy distorts and mutalates the truth in a manner that is self-identity immoral, obscene, and subversive to human flourishing. 26. In September 2018, Plaintiff Guidry and other Plaintiffs asked the library administration if they could conduct a Bible Study while the Drag Queen Story hour was taking place or at any other time. The Library rejected their request because the Library s goal is to endorse Secular Humanism in a manner to show that it is the official religion of the State. The Library is not a proponent of diversity or free speech. It is an advocate for a narrow version of religious moral relativism.
20 27. Pastor Penkoski asked the Lafayette Library if he could be given an opportunity to conduct a rebuttal session immediately following the Drag Queen Story Hour, where he would call into question the plausibility of the transgender ideology and question the fundamental precepts of Secular Humanism. The Library denied Pastor Penkoski s request because its employees believe that they are entitled to usurp the Establishment Clause because they do not know the objective difference between real and fake, right and wrong, and secular and non-secular. 28. Just as self-identified transgenders have the right to self-identify as transgender under the Free Exercise Clause, Plaintiff Sevier has the right to self-identify as a objectophiles. Plaintiff Sevier does self-identify as an objectophile, who married a radiant object in New Mexico with female like features. 29. Plaintiff Sevier, a former rule of law command Judge Advocate General, contacted the Lafayette Library and asked if he could conduct the objectophile story hour to a group of children. Minors such as Nila Frederiksen, the poster child of abusing the me too movement. (Nila Frederiksen is expected to step forward at any moment to accuse Supreme Court Justice nominee Justice Kavanaugh of sexually harassing her as well #me too). Plaintiff Sevier offered to allow Defendant Elberson herself to hand select the books for the objectophile story hour since she self-identifies as a person of tolerance and diversity so that the Library can further perfume the facility with its wisdom, manifesting a more logically consistent endorsement of the Secular Humanism that would actually accord with concepts of equal treatment by state actors. The Library denied Plaintiff Sevier s request and was incredibly hostile towards him because the Library is not really an advocate for tolerance,
21 diversity, and unity. The Library is exclusively interested in endorsing the most popular version of Secular Humanism as advocated by the LGBTQ church and the DNC ad nauseum because the employees of the Library have permitted themselves to become brainwashed by a shallow faith-based system that is immensely irrational. 30. Plaintiff Sevier approached the Red River Parish and asked that the Parish either legally recognize his out-of-state marriage or that the Parish issue him a new marriage license. The Parish denied his request for arbitrary reasons. 31. Throughout Louisiana, the Parishes are issuing marriage licenses to self-identified homosexuals based on their sexual orientation or self-asserted sex-based identity narratives. The Governor and State officials are providing full marriage benefits and privileges to legally married self-identified homosexuals but not to self-identified polygamists and objectophiles for procedural and moral reason based on state law, not Federal Constitutional law. The distribution of the a constellation of benefits to marriage self-identified homosexuals by the implementation and enforcement of policies that the Governor and Attorney General oversee is a use of taxpayer dollars that the Plaintiffs object to. The Plaintiffs have been brutalized, targeted, threatened, libeled, stalked, in some cases assaulted, and victimized by the LGBTQ community for recognizing that LGBTQ ideology is removed from reality, obscene, immoral, non-secular, and nothing more than a pathetic attempt to misuse government in an attempt to explain away the natural feelings of shame and inadequacy that comes from engaging sexual immoral conduct that is as self-evidently evil as rape by trick. The government is not a church. It is not a redeemer. 32. The Plaintiffs are members of the Special Forces of Liberty. The Special Forces Of Liberty are working on a series of legislative proposals with the State House and Senate that will have
22 monumental impact on the annual income of the state. As individuals who pay taxes in this State and who use the public library, the Plaintiffs have a special concerns as to how the State appropriates tax dollars. See DE Special Forces Of Liberty See the Life Appropriation Act (a bill that defunds facilities that are providing convenience abortions because such abortions are non-secular and because such appropriations have the effect of excessively entangling the government with a religion. 33. There are medical experts, some of whom have testified under oath in this case, that, just as there is no evidence that a rape gene exists there is no evidence that a gay gene exists either and that sexual orientation does not have anything to do with immutability. (DE Dr. King 1-20; DE Dr. Cretella 1-20; see the Amicus Briefs of the Coalition Of Doctors Defending Reparative Therapy and the Center For Garden State Families). In fact, these medical experts have attested that it is deeply dishonest for anyone to pretend that there is such thing as a gay gene or the homosexuality has anything to do with immutability whatsoever. 34. There are former gay activists, some of whom have testified under oath in this case, who at one point sincerely self-identified as homosexual and indoctrinated themselves with the LGBTQ ideology, only to completely leave the lifestyle behind, converting to a totally different sex-based identity narrative. These former self-identified homosexuals, some of whom have appeared under oath in this case, have attested that homosexuality is inseparably linked to religion of Secular Humanism. (DE _ Quinlan 1-37; DE _ Pastor Cothran 1-50; DE _ Dr. King 1-20; D; DE _ Goodspeed 1-20; DE _ Grace Harley 1-25; DE 9 Kohl 1-12). See Amicus Briefs of the Center For Garden State Families; American Family Association of PA; National Alliance of Black Pastors; the Coalition of Doctors Defending Reparative Therapy. They have
23 also attested to how depraved, intolerant, immoral, dehumanizing, and dishonest homosexual orthodoxy is. These former gay activists were radically transformed by the personalized truth of the new testament gospel. 35. Many licensed ministers, some of whom have testified under oath in this case, who are experts in religion, have attested that homosexuality, sexual orientation ideology, transgender ethos, and parody marriages, to include gay marriage, are inseparably linked to the religion of Secular Humanism. DE 24 Pastor Cuozzo; 1-21; DE 17 Pastor Farr 1-33; DE 8 Pastor Penkoski 1-34; DE 25 Pastor Cairns 1-30; See Amicus Briefs of the National Alliance of Black Pastors. These pastors have testify under oath that when a person says that they were born in the wrong body, that there are more than two genders, that people can be born gay, that people can come out of an invisible closet and be baptized gay, and that to disagree with the LGBTQ community makes a person a bigot amounts to a series of unproven faith-based assumptions and naked assertions that are implicitly religious and predicated on emotional non-sense that the cannot be used as a basis to usurp the First Amendment Establishment Clause. 36. The Supreme Court has already recognized that non-institutionalized religions are regulated by the Establishment Clause in Torcaso v. Watkin s, 367 U.S. 488 (1961) and Edwards v. Aguillard, 482 U.S. 578 (1987) stating that among religions in this country, which do not teach what would generally be considered a belief in the existence of God, are Buddhism, Toaism, 5 Ethical Culture, Secular Humanism, and others. A majority of the Federal Courts of appeals have also recognized that Secular Humanism is a religion for purposes of the First Amendment Establishment Clause. Because LGBTQ orthoxody, like abortion ideology, is inseparably linked 5 See also Washington Ethical Society v. District of Columbia, 101 U.S. App. D.C. 371, 249 F.2d 127 (1957); 2 Encyclopaedia of the Social Sciences, 293; J. Archer, Faiths Men Live By , (2d ed. revised by Purinton 1958); Stokes & Pfeffer, supra, n. 3, at 560. Welsh v. U.S, U.S. 333 (U.S. Cal. June 15)
24 to the religion of Secular Humanism, it means that the Defendants are bound by First Amendment Establishment Clause pursuant to Article VI through the Fourteenth Amendment to stop enforcing any policy that directly or symbolically respects LGBTQ orthoxody. 37. The LGBTQ community is organized, full, and provide[s] a comprehensive code by which individuals may guide their daily activities. 6 Delta Lambda Phi is not a secular organization. It is faith-based church has set out on a great commission to convert minors to its belief system that denies common sense. Delta Lambda Phi can hold the Drag Queen Story hour on private property and it engages in its destructive efforts to evangelize minors in a manner that is sexually, emotionally, intellectually, and racially exploitative. 38. Plaintiff Sevier, as a self-identified objectophile, moved to intervene in many same-sex 7 marriage actions under Fed. R. Civ. P. 24 as a member of the true minority of sexual orientation. Every time Plaintiff Sevier moved to intervene, the homosexual litigants opposed his intervention. In Brenner, Judge Hinkle found that the legal basis for man-object marriage 6 In Real Alternatives, Inc. v. Burwell, 150 F. Supp. 3d 419, (M.D. Pa. 2015), aff'd sub nom. Real Alternatives, Inc. v. Sec'y Dep't of Health & Human Servs., No , 2017 WL (3d Cir. Aug. 4, 2017), the court stated: we detect a difference in the philosophical views espoused by [the plaintiffs], and the secular moral system[s]...equivalent to religion except for non-belief in God that Judge Easterbrook describes in Center for Inquiry, 758 F.3d at 873. There, the Seventh Circuit references organized groups of people who subscribe to belief systems such as Atheism, Shintoism, Janism, Buddhism, and secular humanism, all of which are situated similarly to religions in everything except belief in a deity. Id. at 872. These systems are organized, full, and provide a comprehensive code by which individuals may guide their daily activities. Instead of having a cross or the ten commandments, the LGBTQ church has the gay pride flag and their own commandments, such as if you disagree with LGBTQ ideology you are a bigot worth marginalizing. The unproven naked truth claims evangelized by the LGBTQ church such as (1) there is a gay gene, that (2) people can be born in the wrong body, that (3) same-sex sexual activity checks out with the human design, that (4) same-sex buggery is not immoral, and that (5) people come out of the closest baptized gay consists of a series of unproven faith based assumptions that are hyper religious and take a huge amount of faith to believe are even real, since these truth claims buck common sense and are more likely than not shallow qualifiers hoping to justify immoral sexual conduct that is indecent, immoral, and questionably legal. 7 Bradacs v. Haley, 58 F.Supp.3d 514 (2014);; B renner v. Scott, 2014 WL (2014);; General Synod of The United Church of Christ v. Cooper, 3:14 cv 213 (WD. NC 2014);; K itchen v. H erbert, 755 F. 3d 1193, 1223 (CA );;;; Bostic v. Schaefer, 760 F.3d 352 (4th Cir. 2014);; M ajors v. Horne, 14 F. Supp. 3d 1313 (Ariz. 2014);;;; Deleon v. Abbott, 791 F3d 619 (5th Cir 2015);; Tanco v. Haslam, 7 F. Supp. 3d 759 (MD Tenn. 2014);; Bourke v. Beshear, 996 F. Supp. 2d 542 (WD Ky. 2014);; and Obergefell v. Hodges, 135 S.Ct (2015)
25 removed from reality. (See Exhibits). The Plaintiffs agree with Judge Hinkle that all self-asserted sex-based identity narratives that are questionable real, moral, and decent are all non-secular in nature and have the potential to be removed from reality, which makes them non-secular. 39. Man-man, woman-woman, man-object, man-animal, and man-multi-person marriage are all equally not part of American heritage and tradition (See the Amicus Brief by WW Bridal and the American Family Association - discourse on the historic, consent, and total-equality norm) States have a compelling interest in upholding community standards of decency. According to the Supreme Court, to simply adjust the definition of obscenity to social realities has always 9 failed to be persuasive before the Courts of the United States. Many Courts have held positions such as: any school boy knows that a homosexual act is immoral, indecent, lewd, and obscene. Adult persons are even more conscious t hat this is true. Schlegel v. United States, 416 F. 2d 1372, 1378 (Ct. Cl. 1969). The Defendants know that by enforcing, recognizing, favoring, and endorsing gay marriage policies, sexual orientation discrimination statutes, and policies that treat transgenderism as if it was plausible that they are eroding community standards of decency and desensitizing our citizens in a manner that is depersonalizing, out of sync with common sense, and subversive to human flourishing. At some point, it is going to have to start registering with progressives that to progress towards savagery is not progress, it is stupid. The Plaintiffs do recognize the right for anyone to self-identify as anything they want to under the Free 8 See Paris Adult Theatre I v. Slaton, 413 U.S. 49, at 63, 69 (1973) see the State s Constitution. 9 Ginsberg v. New York, 390 U.S. 629, , 88 S.Ct. 1274, 20 L.Ed.2d 195 (1968), Mishkin v. State of New York, 383 U.S. 502, 509, 86 S. Ct. 958, 16 L. Ed. 2d 56 (1966), and Bookcase, Inc. v. Broderick, 18 N.Y.2d 71, 271 N.Y.S.2d 947, 951, 218 N.E.2d 668, 671 (1966).